UNITED STATES ENVIRONMENTAl PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

MAR ·19 2014 

MEMORANDUM 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: Responses to Public Comments Concerning the Registration Review of Methyl 

Bromide (PC Code 053201) from EPA Docket ID No.: EPA-HQ-OPP-2013-

0269 

FROM: 

THRU: 

Bill Chism, Ph.D., Senior Biologist 

Biological Analysis Branch 

Science 

Cynthia 

Information 

Doucoure, Environmental 

and Analysis Branch 

Protection Specialist C' ~ 

Biological and Economic Analysis Division (7503P) 

Diann Sims, Chief ){}!2./L-4-~~ fY~<i) Science Information and Analysis Branch 

Amet Jones, Chief /) ~~) Biological Analysis Branc~, '( 

Biological and Economic Analysis · ision (7503P) 

TO: Susan Bartow, Chemical Review Manager 

Risk Management and Implementation Branch 4 

Pesticide Re-evaluation Division (7508P) 

Product Review Panel Date: February 26, 2014 

Through this memo, BEAD is responding to comments about the label report and general usage 

submitted in regards to the registration review of methyl bromide. 

Almond Board of California Comment: The Almond Board provided a description of the use of 

methyl bromide on almonds for soil pest control as well as post-harvest to control insects in 

harvested almonds. They described the use of methyl bromide for control of soil pests of replant 

disease/disorder, nematodes, and/or other soil pathogens such as oak root fungus (Armillaria) or 

bacterial canker. They described its post-harvest use for control of Indian meal moth, red flour 

beetle, and confused flour beetle. 

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BEAD Response: BEAD appreciates the updated information on use rates and amounts used for 

soil and post-harvest fumigation for California almonds. References directing us to relative 

performance data would be helpful if BEAD is asked to conduct a benefit assessment. 

Idaho Potato Commission Comment: The Idaho Potato Commission, the Idaho Grower 

Shippers Association and the Idaho potato industry provided information on their program in 

conjunction with USDA-APHIS to eradicate the Pallida variant of the potato cyst nematode. 

They describe the sensitive nature of crops like potatoes to soil-borne pathogens like nematodes 

and the potentially devastating effect they can have if not properly controlled on yield, quality, 

and access to foreign markets. 

BEAD Response: BEAD appreciates the information on the use of methyl bromide for potato 

cyst nematode control and its potential to negatively impact potato production. The EPA works 

closely with USDA-APHIS to ensure the availability of effective control methods for quarantine 

uses. 

Methyl Bromide Industrial Panel (MBIP) Postharvest Use Comment: MBIP points out that the 

majority of post-harvest fumigations with methyl bromide are for the control of quarantine pests 

on both imported and exported products. 

BEAD Response: BEAD appreciates the information on the value of methyl bromide for control 

of quarantine pests on imports and exports. The EPA works closely with USDA-APHIS to 

ensure the availability of methyl bromide for these types of quarantine uses. 

Methyl Bromide Industrial Panel (MBIP) Pre-plant Soil Use Comment: MBIP points out that 

the use of methyl bromide has been steadily declining with only California strawberry fruit 

approved for a critical use exemption in 2014 and that stocks of methyl bromide produced before 

2005 are also declining. MBIP stated their concern that the Chemical Profile describes past use 

and usage information while they predict future use will be greatly reduced 

BEAD Response: BEAD understands that MBIP is concerned that the Chemical Profile (Chism, 

et al, 2013) and SLUA (BEAD, 2012) describe past use and usage. However, the purpose ofthe 

Chemical Profile is to describe current use, not to predict future use patterns. In the Chemical 

Profile BEAD agrees with MBIP' s assertion of reduced use where the document says that future 

use will be limited to quarantine and preshipment sites and a few critical use exemption sites. As 

the registration review process continues BEAD will describe currently allowed uses (e.g. 

quarantine and pre-shipment) and those uses that have been phased out. 

Northwest Horticultural Comment: The Northwest Horticultural Council provided information 

on the post-harvest fumigation of cherries to meet the quarantine requirements for export to 

Australia, Japan, Korea, and New Zealand. They also described their efforts to find alternatives 

to methyl bromide for control of quarantine and non-quarantine pests. 

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BEAD Response: BEAD appreciates the information on current post-harvest use patterns of 

methyl bromide and the Council's work to find alternatives. The EPA works closely with 

USDA-APHIS to ensure the availability of methyl bromide for quarantine uses. 

Dr. Joe Noling, University of Florida Comment: Dr. Noting describes the research on methyl 

bromide and alternatives, the fumigant safety record, and impacts of buffer zones and 

educational programs. 

BEAD Response: BEAD appreciates the information on the current research on methyl bromide 

and alternatives, the safety record of fumigants in Florida, and the impacts of buffer zones and 

educational programs for Florida agriculture. References directing us to relative performance 

data would be helpful if BEAD is asked to conduct a benefit assessment. 

American Farm Bureau Federation (AFBF): The AFBF urges the Agency to permit producers 

continued access to methyl bromide consistent with Montreal Protocol requirements. I just 

noticed a comment about the Montreal Protocol/CUEs. It says, "With respect to methyl bromide, 

we recognize that the Montreal Protocol affects availability and use of this chemical. 

Nevertheless, given the lack of an affordable, effective alternative, we urge the Agency to permit 

producers continued access to the chemical consistent with phase-out dates under the law. 

AFBF supports the use ofafair, science-basedprocessfor Critical Use Exemptions (CUEs) of 

methyl bromide. " 

BEAD Response: BEAD has worked with applicants, the Department of Agriculture, and 

Department of State for the last twelve years to develop critical use exemptions. The U.S. 

government continues to submit and defend critical use exemptions for all the applicants that can 

demonstrate that the alternatives are not technically and economically feasible. 

Sources: 

Almond Board of California. Comments for Methyl Bromide Fumigant Registration Review; 

Docket: EPA-HQ-2013-0269-0018. Date: November 25,2013. Gabriele Ludwig 

American Farm Bureau. Comments for Methyl Bromide Fumigant Registration Review; 

Docket: EPA-HQ-2013-0269-0012. No Date 

Chism, W., C. Doucoure, D. Berwald. 2013. BEAD Chemical Profile for Registration Review: 

Methyl Bromide (053201). Office of Pesticide Programs, U.S. Environmental Protection 

Agency 

Idaho Potato Commission. Registration Review; Pesticide Dockets Opened for Review and 

Comment Docket ID EPA-HQ-OPP-2013-0269-0011. Date: November 25,2013 

Methyl Bromide Industry Panel, LLC. Docket: EPA-HQ-OPP-20 13-0269-0015. Post Harvest 

Uses of Methyl Bromide. Date: November 25, 2013 

BEAD. 2012. Methyl bromide (053201) Screening Level Usage Analysis (SLUA), May 30, 

2012. Biological and Economic Analysis Division Office of Pesticide Programs, U.S. 

Environmental Protection Agency 

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Methyl Bromide Industry Panel, LLC. Docket: EPA-HQ-OPP-2013-0269-0015 Pre-Plant Soil 

Uses of Methyl Bromide. Date: November 25,2013 

Northwest Horticultural Council. Docket: EPA-HQ-OPP-2013-0269-0016. Registration Review 

of Methyl Bromide. Date: November 25, 2013 

University of Florida, Institute of Food and Agricultural Sciences. Docket No: EPA-HQ-OPP-2013-

0269-0019. Comments Concerning Notice ofOpening ofFumigant Registration Review, 

78 Fed. Reg 59021-59023, September 25,2013: Docket No: EPA-HQ-OPP-2013:0244, 

Ethylene oxide Date: November 25, 2013 

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